Facts of the Case

Provided by Oyez

Damon Landor, a devout Rastafarian, vowed as part of his faith never to cut his hair—a religious commitment known as the Nazarite Vow. Incarcerated in 2020, Landor was first held at the St. Tammany Parish Detention Center and later at LaSalle Correctional Center, both of which allowed him to maintain his hairstyle in accordance with his religious beliefs. After approximately five months and with three weeks left in his sentence, Landor was transferred to Raymond Laborde Correctional Center. Upon arrival, Landor proactively explained his religious practices and presented documentation of previous accommodations, including a copy of a federal court decision supporting similar claims. An intake guard disregarded his documentation, summoned the warden, and upon Landor’s inability to produce immediate additional proof of his beliefs, guards forcibly handcuffed Landor and shaved his head.

Following his release, Landor sued the Louisiana Department of Corrections and Public Safety, its Secretary James LeBlanc, the correctional center, and Warden Marcus Myers, asserting claims under the Religious Land Use and Institutionalized Persons Act (RLUIPA) and 42 U.S.C. § 1983 for violations of his federal constitutional rights, as well as state law claims.

The U.S. District Court for the Middle District of Louisiana dismissed Landor’s individual-capacity RLUIPA claims for money damages, holding such relief unavailable under controlling Fifth Circuit precedent. The U.S. Court of Appeals for the Fifth Circuit affirmed, relying on its prior decision in Sossamon v. Lone Star State of Texas, and rejecting Landor’s arguments that subsequent Supreme Court authority or other legal developments altered that result.

Questions

  1. May an individual sue a government official in his individual capacity for damages for violations of the Religious Land Use and Institutionalized Persons Act (RLUIPA)?

Conclusions

  1. Individuals cannot sue state prison officials in their individual capacities for monetary damages under the Religious Land Use and Institutionalized Persons Act (RLUIPA). The Spending Clause—Congress's constitutional power to spend money for the general welfare—does not allow Congress to impose personal lawsuit liability on individuals who never voluntarily and knowingly agreed to face such liability under a Spending Clause statute. Justice Neil Gorsuch authored the 6-3 majority opinion of the Court.

    The Spending Clause gives Congress the power to spend—not to regulate. When Congress attaches conditions to federal grants, those conditions bind only the entities and individuals who knowingly accept them, much like a contract. The standard consequence for violating a funding condition is also straightforward: Congress cuts off the money. Any additional sanction—such as personal exposure to private lawsuits for damages—requires the voluntary and knowing consent of whoever must bear it. Courts determine whether that consent exists by applying contract principles: just as a breach-of-contract lawsuit cannot proceed against someone who never signed the contract, a Spending Clause lawsuit cannot proceed against someone who never agreed to answer it. RLUIPA required state prison systems to consent to private suits as a condition of receiving federal funds. Louisiana's Department of Corrections accepted that deal. The individual prison officers did not. They never personally agreed with the federal government to face RLUIPA liability, so the suit cannot proceed against them.

    None of the counterarguments overcome the missing consent. The four requirements for Spending Clause legislation set out in South Dakota v. Dole supplement—they do not replace—the consent requirement. Agency law provides no shortcut either: when an employer enters a contract, that contract does not automatically make the employer's workers personally liable to the other contracting party. The fact that officers receive paychecks partly funded by federal dollars also fails, because accepting that logic would let Congress regulate virtually any individual in the country so long as some federal money once passed through their employer's hands—an effectively unlimited police power inconsistent with a federal government of enumerated powers. Finally, the Necessary and Proper Clause—which lets Congress use means reasonably adapted to executing its enumerated powers—does not save the claim. The correct question is whether suing nonconsenting individuals is a necessary and proper means of protecting Congress's power to spend money. It is not. Unlike the anti-bribery statute upheld in Sabri v. United States, which directly guarded federal funds from theft and corruption, suits against individual prison officers do nothing to protect federal money; they advance RLUIPA's religious-liberty goals through other means. Permitting Congress to route around the consent requirement via the Necessary and Proper Clause would hand the federal government direct regulatory power over countless nonconsenting individuals in areas the Constitution reserves to the states.

    Justice Ketanji Brown Jackson dissented, joined by Justices Sonia Sotomayor and Elena Kagan, arguing that the Spending Clause grants Congress the power to legislate—not merely to negotiate—and that the majority's strict consent-to-personal-liability rule has no basis in constitutional text, in South Dakota v. Dole, or in decades of precedent upholding Congress's authority to regulate individuals connected to federally funded programs through means that go beyond direct contractual counterparties.